Revolut Ltd · DRN-6130570

Complaint Miss E complains that Revolut Ltd didn’t refund her losses when she made payments to a number of unlicensed gambling websites. Background The background to this complaint and the large number of payments involved was set out in the Investigator’s view. I don’t intend to repeat it in the same detail here. Instead, what follows is a summary of the key facts: Miss E has explained that she suffers from a gambling addiction, which can result in periods of compulsive spending on gambling websites. To help manage this, she registered with Gamstop (which is a voluntary self‑exclusion scheme followed by UK‑regulated gambling operators). This meant that she was no longer able to deposit funds with regulated, mainstream gambling providers operating in the UK. In October 2024, Miss E also informed Revolut of her gambling difficulties. Despite these steps, Miss E says she was subsequently targeted online by a number of overseas companies operating online casinos. She explained that these businesses were set up in a way that allowed them to circumvent protections intended for vulnerable customers like her. In particular, they did not participate in GamStop. Instead, they appear to have specifically targeted vulnerable individuals who might want to make gambling payments outside of the GamStop scheme. These companies also typically receive funds using merchant categorisation codes that did not indicate gambling activity. As a consequence, it can be harder for a firm to spot payments being made for gambling purposes. Between December 2024 and June 2025, Miss E made a very large number of card payments which she says were made during episodes of compulsive spending behaviour. She says these payments were deposits to unauthorised gambling websites operating outside the UK. Miss E later contacted Revolut and asked it to recover the funds she had spent, or otherwise reimburse her. Revolut declined to do so. In particular, it didn’t agree to her request that it raise chargebacks in respect of the transactions, which was how Miss E initially framed her complaint. Miss E was unhappy with Revolut’s response and referred her complaint to this service. The complaint was first considered by one of our Investigators, who upheld it in part. The Investigator noted that Miss E had made a very high number of transactions over the relevant period, and that it was difficult to be certain that all of them were made in the same circumstances or related to gambling activity. However, the Investigator had identified two clear groups of payments to specific merchants (referred to in this decision as Merchant A and Merchant B). She felt Revolut ought reasonably to have been concerned about the nature and pattern of those payments given what it knew about Miss E’s vulnerability and should have intervened. She said that, had it done so, some of those payments would have been prevented. Miss E also pointed to a particular transaction that Revolut initially blocked due to fraud concerns, but which was successfully processed shortly afterwards. This payment wasn’t

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made to either Merchant A or Merchant B, but the Investigator concluded that it should be refunded too. The Investigator didn’t think Revolut had done anything wrong in relation to Miss E’s request that it raise chargebacks on her behalf. Miss E accepted the Investigator’s conclusions. Revolut did not agree with the Investigator’s opinion, and as a result the case has been referred to me to consider and issue a final decision. Findings I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. As a starting point, the general legal position is that a payment service provider is required to process payments and withdrawals that have been authorised by its customer. This obligation arises under the Payment Services Regulations 2017 and the relevant account terms and conditions. At the outset of her complaint, Miss E asked Revolut to raise chargebacks in respect of the disputed transactions. The Investigator explained in detail why, in her view, a chargeback wouldn’t have been likely to succeed in the specific circumstances of this case. Miss E accepted the Investigator’s conclusions on that point. In light of that, and given there is no longer a dispute between the parties about chargebacks, I don’t think it’s necessary to repeat that reasoning here. However, I have gone on to consider whether Revolut treated Miss E fairly in light of her known vulnerabilities. Principle 6 of the FCA’s Principles for Businesses requires a firm to pay due regard to the interests of its customers and treat them fairly. PRIN 1.2.1G sets out that the extent of a firm’s obligations under the Principles will vary with the characteristics of the customer concerned. I’ve taken that into account here. I have also taken into account the FCA’s publication ‘Guidance for firms on the fair treatment of vulnerable customers’. That guidance explains at section 1.1 that: “A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.” It’s not contentious that Miss E was vulnerable to a specific type of potential harm as a result of her gambling addiction. The FCA guidance explicitly recognises addiction as a potentially relevant driver of vulnerability. It says that vulnerability may arise from health factors, including conditions or illnesses that affect a person’s ability to make decisions, including addictions. It clearly wouldn’t be fair or reasonable to expect Revolut to have taken steps to protect Miss E from this risk unless it knew, or ought reasonably to have known, about her vulnerability. However, on the evidence I’ve seen, I’m satisfied that Revolut was made aware of this characteristic on multiple occasions. Miss E first notified Revolut of her gambling addiction in or around October 2024 when raising it as part of a separate complaint. During the period relevant to this complaint, she referred to it again in a number of messages to Revolut. For example, on 12 April 2025 she said: “As I have told Revolut on many occasions now, I have a gambling addiction…” And on 27 April 2025 she said: “… I have been having significant mental health issues currently where I go through episodes of dissociation and essentially gamble more than I can afford. I am registered with GamStop however there are illegal overseas casinos that prey on people like me …”

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I have reviewed the pattern of activity on Miss E’s account. I agree with the Investigator’s conclusion that, when she began making multiple payments to Merchants A and B in quick succession, it ought reasonably to have occurred to Revolut that there was a real prospect she had again been drawn into gambling with unlicensed overseas providers. Miss E made her first payment to Merchant A on 29 March 2025 and, within less than a month, went on to make more than 60 payments to that merchant. On 25 April, she attempted a payment to Merchant A which was declined because there were no funds in her account. At that point, I think the frequency of the payments being made and the fact that they’d resulted in her completely emptying her account ought to have given Revolut cause for concern. She made her first payment to Merchant B on 1 May 2025 and then made payments in similarly high volumes and with a similar velocity. In the context of what Revolut already knew about Miss E’s vulnerability, I think it should’ve been within its contemplation that this activity related to gambling. The Investigator identified a payment to Merchant B on 6 May at 11:37am as the point at which those concerns should’ve resulted in action and I’d agree with that conclusion. Miss E has described her condition as one in which, at certain times, her decision‑making becomes automatic and impulsive. She says she makes gambling payments instinctively, without properly considering the consequences, and that this leads to significant financial losses that she cannot afford. In those circumstances, I think a proportionate intervention by Revolut would likely have had a meaningful impact. By stepping in at the points set out above, it would effectively create a pause between the psychological trigger and the payment. Revolut could’ve given Miss E an opportunity to regain control and reflect on what she was doing. On a case‑by‑case basis, it could then have blocked specific merchants that were giving rise to concern. Finally, I’ve also noted that Miss E attempted a payment on 31 December 2024 that wasn’t to either of these merchants, but does appear to have been in connection with an unlicensed gambling operator. This payment was attempted at 9pm, but Revolut blocked it citing fraud concerns. I think it ought, then, to not have allowed payments to that merchant to be made around 50 minutes later, so I’m satisfied that payment should be refunded too. I recognise that such an approach would not have eliminated all losses. Revolut wasn’t and couldn’t be expected to prevent all potential harm. However, in my view, had Revolut taken proportionate steps of this nature, it would likely have reduced and limited the financial harm that Miss E went on to suffer. Final decision For the reasons I’ve explained above, I uphold this complaint in part. If Miss E accepts my final decision, Revolut Ltd should pay her: - All payments to Merchant A from and including the payment on 25 April 2025 at 7:53am. - All payments to Merchant B from and including the payment on 6 May 2025 at 11:37am. - The miscellaneous payment she made on 31 December 2024. It should also add 8% simple interest per annum to these payments calculated to run from the date they debited her account until the date any settlement is paid. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss E to accept or reject my decision before 26 May 2026. James Kimmitt

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Ombudsman

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